We also assist our clients with the development of practices to ensure the plans are updated in accordance with ongoing facility changes and regulatory requirements. The SPCC Plan must be updated whenever there is a spill and whenever there is a change in facility design, construction, operation, or maintenance which materially affects the facility’s potential for the discharge of oil. This update should be fully implemented as soon as possible, but no later than six months after such change occurs. At a minimum, a complete review and evaluation of the SPCC Plan must be performed once every five years, and the SPCC Plan must be updated, if necessary, within six months of the review.